Ford Code of Human Rights, Basic Working Conditions and Corporate Responsibility
Pre-Site Visit Facility Survey
Date
Location / Facility
September 1, 2012
Michigan Assembly Plant, Wayne, Michigan
Perception and Understanding of Code
1. In your opinion, what is the greatest value-add of conducting human rights assessments at Ford’s owned and
operated facilities?
The greatest value in conducting these assessments serves as a reminder of the many basic rights our
employees take for granted that are not rights given to all employees in all countries. These assessments also
give us the opportunity to make sure the safe holds and processes we have in place to guard and monitor these
rights are working properly and can be adjusted or reinforced if necessary.
2. When you look at the code, and imagine using it to assess current practice at Ford facilities, what are the
greatest areas of non-compliance that you might predict? How do you think management, workers and
employee representatives at Ford facilities will view these assessments?
It is not anticipated that there will be any areas on non-compliance at Michigan Assembly Plant. Due to the recent
addition of another operating shift and a recent major model product launch, the organization will continue to
monitor salaried work hours to ensure continued compliance.
It is not anticipated there will be any strong reaction either positive or negative to the assessments.
Facility Conditions
Human Rights
In order to gauge human rights risks, it is imperative that business enterprises identify and assess any actual or
potential adverse human rights impacts with which they may be involved either through their own activities or as a
result of their business relationships. Please answer the following questions to describe how your facility
approaches assessment and management of human rights risks.
1. In your opinion, what does upholding human rights mean to your facility?
Upholding human rights at Michigan Assembly Plant means providing an environment in which employees can
work safely, without fear of discrimination or harassment by treating them equally and with respect as governed
by the laws of the government and policies of the company.
2. How is the preservation of human rights monitored in your facility?
Preservation of human rights is maintained by strict adherence to corporate policy and government laws. These
rights are monitored through multiple annual audits, employee surveys, and mechanisms to report violations of
these rights for thorough investigation and resolution, such as the harassment hotline or the grievance process.
3. How is your facility working to reduce human rights risks? Please describe any particular processes or
initiatives.
Employees are trained in different forums about corporate policies supporting human rights such as Diversity
Training and Standards of Corporate Conduct Training. Corporate policies and government laws regarding
employee rights are prominently posted throughout the facility. Communication regarding different policies,
initiatives, and recent events are distributed to employees through Safety Stand Downs, Bulletins, Newsletters,
Email, and in Team Meetings. Skip Level Meeting and surveys are conducted inquiring about employees’
perspectives and opinions about different aspects of their employment. Surveys include the Pulse Survey and the
Employee Engagement which was recently opened to hourly employees for participation.
4. How is your facility monitoring human rights risks?
Results of the surveys and skip levels referenced above monitored and shared with Human Resources and Plant
Leadership for action planning to address issues raised. Plant Leadership and UAW Representatives are in
constant communication regarding issues as they arise related to the rights of the employees and work together
to resolve issues as quickly as possible.
5. How are you remediating any non-compliance to human rights policies or addressing identified human rights
risks?
If after investigation, non-compliance is identified, if related to an individual, the proper penalty is administered
through corporate policy. Any appropriate remuneration is administered if the non-compliance is related to wage
or benefit administration. Appropriate training is redeployed if necessary.
6. Do you believe that you are making progress in minimizing human rights risks? What additional support do
you believe is necessary in order to making continuous improvement towards upholding human rights?
We believe we provide an environment that respects human rights and have made strides in ensuring we
continue to protect these rights. With the significant number of employees on site, over 5,000, it is difficult to
conduct frequent and throughout training events to keep our employees aware of efforts and policies pertaining to
human rights. Additional resources to assist in facilitating training would be appreciated.
Working Conditions
1. Please describe how you meet each of the facets of “Basic Working Conditions” as outlined in the Code of
Human Rights, Basic Working Conditions, and Corporate Responsibility. Use the following chart to outline: i)
the policy / law(s) followed in order to meet these principles of “Basic Working Conditions” as outlined in
Policy Letter 24, ii) the process your facility undertakes in order to implement such policy / law correctly, and,
iii) where these documents are housed.
Policy(s) / Law(s) Followed
Child Labor
• Fair Labor Standards Act
• Fair Labor Standards Act
• UAW Collective Bargaining
Agreement
Compensation
Forced Labor
Freedom of
Association and
Collective Bargaining
• Fair Labor Standards Act
• At Will Employment
• National Labor Relations Act
• UAW Collective Bargaining
Agreement
Process to Implement Policy Correctly
• Plant does not employee candidates without
either High School Diploma or age of 18.
• Salaried employee compensation if developed by
the Compensation Office in the HR Organization
using competitive analysis and a pay for
performance philosophy for the annual
compensation plan.
• Hourly employee compensation is determined
through the collective bargaining process and is
audited by the Wage Administration Office of the
Labor Affairs Department.
• Forced labor is prohibited, Ford is an at will
employer, employees can leave the company at
any time for any reason.
• Employees have the right to participate in union
member or activies as provided by the National
Labor Relations Act and governed by the National
Labor Relations Board (NLRB). Complaints
regarding company practices can be made
directly to the NLRB for investigation,
determination, and remedy.
Policy(s) / Law(s) Followed
• Company Directive B-110:
Anti-Harassment
• Equal Employment
Opportunity Act
Harassment and
Discrimination
Health and Safety
Work Hours
• Occupation Health and Safety
Administration Guidelines
• Safety Operating System
(SOS)
• Fair Labor Standards Act
• UAW Collective Bargaining
Agreement
Process to Implement Policy Correctly
• MAP has a Zero Tolerance Policy that is strictly
enforced, all complaints are investigated and
employees dispositioned appropriately.
• All new employees are required to participate in
Diversity Training and sign a copy of the
company’s Zero Tolerance Policy brochure.
• Complaints can be directed to Labor Relations,
the Personnel Relations Hotline for investigation
or escalated to the Equal Employment
Opportunity Commission (EEOC) for further
investigation.
• All Health and Safety processes are governed by
the SOS process. Shop floor level, Plant and
Executive reviews take place on a regular basis.
• OSHA Act activity monitors safety activies and
• Salary work hours and compensation are
determined by the FLSA.
• Hourly work hours are negotiated in the collective
bargaining process. Violations of negotiated work
hours are remedied through the grievance
process.
Where are these documents housed?
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Employee related details are maintained on personnel files for both salaried and hourly employees. In
addition People Soft retains records of past and present salaried employees and TWOS retains records of
past and present hourly employees.
Salaried salary ranges and wage structure is maintained by Compensation and Benefits within the Human
Resources structure.
Collective bargaining documents and agreements are maintained by Labor Affairs within the Human
Resources structure.
Hourly wage rates and structure are maintained in the collective bargaining agreements and with the Wage
Administration Office of the Labor Affairs Department.
Grievance Procedure documents are kept on file with the local Labor Relations Offices.
Employee hotline records are maintained by the Personnel Relations.
Human Resources Policies and Procedures are documented and kept on the HR Online Site for salaried
employees on the company intranet site.
Ford Corporate Directives and Policies are stored on the Ford Legal Access SharePoint Site.
2. In the code, it has been made explicit that Ford seeks to identify, report, and address any suspicion of human
trafficking in order to adhere to our commitment to ensuring Basic Working Conditions and Human Rights.
a) Within your community, are you aware of or have noticed any human trafficking activity? If so, please
describe.
We are not aware of any issues of human trafficking activity in this community. There have been no instances
reporting or observed.
b) Are you aware of any suppliers or businesses in which you interact that are suspected of or have
been found to engage in activities of human trafficking, directly or indirectly?
We are not aware of any suppliers or businesses we interact with that are suspected or have been found to
engage in any sort of activies of human trafficking.
Corporate Responsibility
1. Please describe how you meet each of the facets of “Corporate Responsibility” as outlined in the Code of
Human Rights, Basic Working Conditions, and Corporate Responsibility. Use the following chart to outline: i)
the policy / law(s) followed in order to meet these principles of “Corporate Responsibility” as outlined in Policy
Letter 24, ii) the process your facility undertakes in order to implement such policy / law correctly, and, iii)
where these documents are housed.
Policy(s) / Law(s) Followed
Community
Engagement and
Indigenous
Populations
Bribery and
Corruption
Environment and
Sustainability
• Ford Corporate Responsibility
Policy
• Policy Letter 13:
Governmental Relationships
and Civic Affairs
• Policy Letter 3: Standards of
Corporate Conduct
• Policy Letter 17: Protecting
Health and the Environment
Process to Implement Policy Correctly
• Ford Global Week of Caring
• Accelerated Action Days
• 16 Hours Paid Community Service Annually
• Annual financial disclosure declaration
• Annual recertification of Standards of Corporate
Conduct Training
• MAP houses the largest solar panel field in the
state of Michigan.
Where are these documents housed?
•
•
•
•
•
•
•
•
Employee related details are maintained on personnel files for both salaried and hourly employees. In
addition People Soft retains records of past and present salaried employees and TWOS retains records of
past and present hourly employees.
Salaried salary ranges and wage structure is maintained by Compensation and Benefits within the Human
Resources structure.
Collective bargaining documents and agreements are maintained by Labor Affairs within the Human
Resources structure.
Hourly wage rates and structure are maintained in the collective bargaining agreements and with the Wage
Administration Office of the Labor Affairs Department.
Grievance Procedure documents are kept on file with the local Labor Relations Offices.
Employee hotline records are maintained by the Personnel Relations.
Human Resources Policies and Procedures are documented and kept on the HR Online Site for salaried
employees on the company intranet site.
Ford Corporate Directives and Policies are stored on the Ford Legal Access SharePoint Site.
2. What local communities or populations do you regularly engage with? What issues are pertinent to them in
relation to Ford’s projects and activities? What is your process to address issues pertinent to such local
communities and populations?
Michigan Assembly Plant engages primarily with members of the Wayne community. The community is primarily
concerned with the environmental and economic impact the facility has on their community. MAP actively
participates in fund raising for charities such as March of Dimes, Juvenile Diabetes Research Foundation, and
Toys for Tots to benefit the members of the community. Employees are encouraged to use their 16 hours of paid
community service each year to benefits the members of the community.
3. How have you incorporated sustainable water strategies in to your facility’s operations? Can you point to any
specific metrics / improvements that have been made and can be quantified? If so, please describe or provide
any relevant documentation that indicates progress. Please contact the Manager, Social Sustainability, if
unfamiliar with Ford’s water strategy and related initiatives to receive additional information.
Michigan Assembly Plant has installed meters within paint shop during the facility change over in 2010. There is
also maintenance PM’s that review the process valves to ensure water leaks are discovered and repaired in a
timely manner. We recover water from the sludge drying process and return that water to the paint pit as makeup water. Body Shop and Stamping review their weld water system to ensure leaks are repaired and we do not
have to add make-up water to those systems.
4. In your opinion, how do you believe sustainable water projects contribute to the health of staff, operations and
the community?
Each project that is written within the plant is reviewed by the Environmental Department to ensure we capture
any increases or decreases to chemical or natural resources. By implementing water reduction projects or
equipment, the plant is able to reduce our dependence on city water as this helps to reduce the overall cost to the
facility and community. We are also viewed as good stewards for attempting to minimize water usage so there is
more available to communities in areas where water is scarce.
5. What initiatives are being undertaken to reduce environmental / health impacts from operations? How is this
contributing to your facility’s ability to move towards being more environmentally sustainable in the long-term?
The facility is constantly working with corporate to find or develop new technology that will help us reduce or
eliminate emissions to the air, energy usage or the use of less hazardous chemicals. At the same time, we work
with vendors to reduce our packaging waste to keep this material out of landfills. The implementation of recycling
programs both within the plant and around the surrounding community will allow us to reduce our footprint of
waste generation from the production of the vehicle lines.
Responsibility for and Implementation of the Code
1. How are you approaching continuous improvement in your facility’s performance, practices and processes in
place to comply with Policy Letter 24?
As part of the manufacturing organization, MAP is continuously involved in evaluating continuous improvement in
many aspects of our operations, including human rights. MAP has several forums, including a joint Ford/UAW
continuous improvement forum to discuss all issues of operations including human rights and safety. MAP will
continue to participate in employee surveys, corporate audits, and mutual growth forums to identify areas for
improvement and develop action plans to continue to improve all aspects of our operation, including human rights.
Additional Information
1. What would you suggest is most important for Social Sustainability to keep in mind in order to make this effort
successful (both in terms of gathering information and creating a sense of partnership and shared purpose
with the facilities)?
Developing educational opportunities and forums for awareness on what Policy Letter 24 is and which human
rights processes are in effect in each Region. Human Rights progress varies greatly by Region and it is valuable
knowledge for all employees to know and understand what progress is being made at all of the facilities in Ford.
2. Any words of wisdom/advice?
Dependent on the Region, many human rights are taken for granted. It would be helpful to be able to provide
more education about how each of the company policies and directives has been put in place to help support our
human rights. Through this process, it has been enlightening to understand all of the efforts taking place,
however it would be impactful for this information to be available to the broader employee population.